This is regarding the confirmation for the guidelines for the Cell S.03.01.R0330/C0010 and S.03.01.R0330/C0020.

As per our understanding,

1.    Amount reported in the cell R0330/C0020 should always be less than the solvency2 amount of contingent liabilities reported in QRT S.02.01.R0740/C0010 as per the xbrl assertion BV397

2.    Amount reported in the cell R0330/C0010 should be equal to the solvency2 amount of contingent liabilities reported in QRT S.02.01.C0010/R0740 as it is the maximum amount reported regardless of probability

Questions :

1.    Do you confirm our understanding?

2.    Do we report regardless of probability in both the QRT S.03.01 and S.02.01? If not, is it possible that after considering probability and risk free term structure, the fair/expected value of contingent liabilities in BS should be lower. Therefore, {S.03.01. R0330/C0010} >= {S.02.01 R0740/C0010}

EIOPA answer

In C0010/R0330 in S.03.01 is requested the maximum amount if possible. When it is not possible it is not reported. In C0020/R0330 in S.03.01 should be reported the SII amount but only for the liabilities for which a maximum value was reported, so that both rows address the same liabilities and could be compared.

When the maximum amount is not reported the company needs to explain it in the RSR (see GL 21 of Guidelines on reporting and disclosure)

S.03.01.C0020/R0330 cannot be higher than S.02.01.C0010/R0740 but may be lower raising an obligation to report it in RSR.